Subject: Please Conserve North Shore Surf: Adverse Wind Farm Effects to Swells and Offshore Surfing Wind Conditions on the North Shore of O‘ahu

Please employ your available means to minimize wind farm harm to North Shore O‘ahu’s surf conditions. Although our letter addresses adverse effects of wind farms to surf, the social and environmental injustices of BOEM’s proposed Ka‘ena Point (O‘ahu North) and the proposed Na Pua Makani Wind Farm in Kahuku are of even graver concern than effects of those wind farms to surf. The North Shore’s September 20 to April 20 surf season is internationally-renowned because our tropical waters receive ocean swells 80 percent of days and on 60 percent of those days, wave faces are groomed by offshore, easterly winds. Large floating wind platforms should not be permitted in North Shore waters (Figure 1) during surf season where they would diffract incoming ocean swells. Since 2005, engineering literature has documented turbulence in the air and increased ground temperatures extending more than 10 miles downwind from wind turbines; the air disturbances of the proposed, relatively inefficient, turbines far exceeds the relatively small amount of energy the turbine harvests. Wind turbine wake turbulence is a double-whammy to our offshore wind flow: it disrupts our prevailing east winds, and, by contributing to warmer land temperature, exacerbates development of upslope onshore winds that are extremely detrimental to surf conditions. To minimize these adverse wake turbulence effects to important offshore winds, any wind turbine situated upwind from a North Shore surf break should be required to shut down when ocean swells are reaching the North Shore (see Figure 1).

Wave Disruption: In May 2016, the Bureau of Ocean Energy Management (BOEM) concluded North Shore waters are suitable for wind development and in July 2016, they offered “Oahu North” for wind farm lease development (Figure 2). The offshore wind farm leases under consideration would entail complex floating structures that would diffract waves (Figure 3, See Figure 1).

Figure 2. Ocean areas under consideration for BOEM wind farm development.Figure 3. Large structures in the water would diffract incoming ocean swells.

Wind Farm Disruption of Offshore Winds: Downwind wake air turbulence of conventional, inefficient, wind turbines results in significant disturbance in downstream winds. Their air disturbance far exceeds the small amount of energy extracted by the wind turbine (Figures 4 and 5). Since at least 2005, scientific engineering journals have documented significant changes in wind speed and direction, increased air turbulence, and increases in on-land air temperature extending distances 10 miles and farther downwind from wind farms.

Figure 4. Wake turbulence, far exceeding the relatively small amount of energy harvested from these very inefficient wind turbines, extends more than 10 miles downwind from the wind farm.Figure 5. Wind speed [meters/second] map based on the ERS-2 satellite. The Horns Rev wind farm, Denmark is indicated (white trapezoid) and a wind wake is seen as dark pixels downstream of the turbines, 25 February 2003, wind direction = 110⁰, wind speed 6.0 meters/second (m/s) (13 mph) (Christiansen and Hasager, Remote Sensing of Environment, October 2005).The typical length-scale of the wind farm wakes is approximately 20 km (12.4 miles) that is independent of the size of the wind farms as well as background meteorology.” (Baidya, J. of Wind Engineering and Industrial Aerodynamics. In Press).

Offshore winds are important on the North Shore because they groom wave faces, hold wave faces up to allow them to build taller and steeper before they break, and contribute to hollow larger longer barrels. Onshore winds ruin surf conditions because they result in bumpy wave faces. The four year-old Kahuku Wind Farm (in full-time operation since February 2014) is disturbing the prevailing east (offshore) winds and increasing the prevalence of onshore winds at Sunset Point surf spots situated 3.4 miles downwind from the wind farm. Winds from 90⁰, when the wind moves “behind the wind farm”, are inconsistent, less filled-in, gustier, and more onshore when the wind turbines are operating. When prevailing winds are from 95 and 100 degrees directions Sunset Point winds are normal, unaffected, not “blocked” or disturbed by the Kahuku Wind Farm and cool down-valley air is not affected because wake turbulence stays offshore from surf spots. Review of data from the Federal, scientific-grade weather station located one mile east (upwind) from the wind farm (http://www.raws.dri.edu/cgi-bin/rawMAIN.pl?hiHKII) confirms the east (90⁰) winds are still there during periods they’re disturbed at Sunset Point; therefore the degradation of the 90⁰winds at Sunset Point can’t be attributed to natural variability or climate change. The Kawailoa Wind Farm is having the same direct effect to offshore wind flow at Chuns Reef and Laniakea surf breaks and the double-whammy is the wind farm’s exacerbation of land heating and development of onshore winds. The proposed Na Pua Makani Wind Farm would be five miles directly upwind from Pipeline (Figure 6), 58% taller than the largest Hawai‘i wind farm, and with each rotor sweeping an area 1.8x (almost 2x) those of the existing Kahuku Wind Farm. Offshore winds are of critical importance to Pipeline, which is among the most important waves in the world. When we expressed concern regarding the adverse effects the Na Pua Makani Wind Farm would have to Pipeline’s offshore winds, the wind developer refuted our concerns (March 7, 2017 Pacific Business News). Since these direct wind farm effects to wind flow and indirect effects to wind direction due to land heating have been documented in the literature since 2005, these adverse effects of Na Pua Makani to Pipeline’s surf conditions would be expected even in the absence of local observations.

On March 15, 2017, Sunset Beach Community Association unanimously agreed to ask for a county law requiring wind turbines situated upwind from the Velzyland to Waimea Bay surf breaks (see Figure 6) to feather their blades so the blades are oriented parallel to the wind, not catching the wind, shut down, during the day, when the most recent swell reading on the NOAA Waimea buoy (Station 51201) is 8-feet, 14-seconds or higher. These are large barrel conditions with wave faces breaking double-overhead, 12-feet (Hawaiian). These swells occur approximately six percent of year-round hours (day and night). When daylight and wind direction are accounted for, this North Shore wind farm shut-down for surf winds would affect fewer than three percent of the hours of the year. To reduce the adverse effect of wind farm wake air turbulence to North Shore surf conditions, it should be illegal, at a bare minimum, for a wind turbine to be operating upwind from a North Shore surf break when these largest, internationally-important, swells occur. To avoid the adverse effect completely, turbine shutdown would need to extend to swells 4-feet, 11-seconds and larger.

Please don’t allow bulky in-water structures to diffract incoming North Shore swells between September 20 and April 20; please require wind farms upwind from the North Shore’s important surf breaks to shut down when swells are reaching the North Shore; and please discontinue use of North Shore wind farms by utilizing less harmful clean energy alternatives as quickly as possible. Ua mau ke ea o ka ʻāina i ka pono.

Just now, shown below, we refined the analysis to use the 2014-2017 period you refer to in your article as the “after” period for operation of the Kahuku Wind Farm and we found the results are the same: the dramatic loss of east winds at Sunset Point is due to something well beyond the minor contributions of natural variability and climate change. The dramatic decrease in winter daytime east/offshore winds frequency and velocity we’re experiencing at Sunset Point is not reflected in the 2014-2017 wind data collected at the James Campbell weather station, one mile upwind from the wind farm. Nor is the dramatic increase in prevalence of side-onshore ENE and NE winds at the Sunset Point surf spots. The east winds we’re sorely missing at Sunset Point during our winter (October 1 through March 31), daytime (8 am to 3 pm) surf season are still present upwind from the wind farm. All of our analyses, to date, refer to these winter months and these daytime hours when winds had been most predictable and reliable. In addition, below we provide new data from a “backyard” weather station a Civil Defense engineer has been operating at his home on Sunset Point since 2015 of interest, even though the wind sensors don’t meet NOAA scientific standards. (The “backyard” weather station belongs to William Osborn; I met him two weeks ago; a building at Comsat is named after him because he was an engineer there for almost 40 years; he is a ham radio operator: KH6KV, his email is [withheld from this public post]@hawaii.rr.com). Here is today’s refined analysis using your 2014 to 2017 analysis period:

Percentage of hours the James Campbell weather station recorded East, ESE, or SE (which are offshore for our local surf breaks) winds:

– before (2002-2009): 47.3% of hours;

– 2014 through present: 40.9% of hours (This slight decline of E, ESE, and SE wind frequency at the “control” site doesn’t reflect the significant reduction in east winds detected at the surf spots).

Percentage of hours the backyard weather station at Sunset Point recorded these East, ESE, or SE winds: 7.6% (!)

Percentage of hours the James Campbell weather station recorded light East, ESE, or SE winds (1-13 mph, offshore winds for surfing):

– before (2002-2009): 15.8% of hours

– after (2014-present): 17.6% of hours. One mile upwind from the wind farm, the east, offshore light winds that are ideal for surfing are more frequent in the 2014 to present period than the pre-wind farm construction period.

Percentage of hours the backyard weather station at Sunset Point recorded light East, ESE, or SE winds since it began operation in 2015: 7.6% of hours (!)

Percentage of hours the James Campbell weather station recorded ENE and NE winds (side shore and side-offshore wind directions less favorable for surfing at many Sunset Point (and North Shore) surf spots):

– before (2002-2009): 23% of hours;

– after (2014 – present): 17.2% of hours (an actual reduction in ENE and NE wind frequency, consistent with UH’s climate change publication). The weaker flow of east winds seems related to this filling in of ENE and NE winds.

Percentage of hours the backyard weather station, installed in 2015 at Sunset Point, recorded these wind direction conditions: 57.5% of hours (!).

Regarding the strength of the E, ESE, and SE (offshore winds): Wind surfers are the most reliant on offshore (E, ESE, and SE) winds of high velocity. During the 2014 to present time period, E, ESE, and SE winds of these higher wind speeds were extremely rare at Sunset Point. The percentage of total winter surf season hours with E, ESE, or SE winds 19-25 mph (for wind surfing) felt at the James Campbell weather station:

– 2002-2009: 10.4% of hours;

– 2014 to present: 6.7% of hours. That these windsurfing winds still occur 6.7% of hours at the weather station on the windward side of the wind farm is remarkable, because during the 2014 to present time period, we have rarely received those winds here, three miles downwind from the wind farm.

Percentage of hours the backyard weather station installed in 2015 at Sunset Point recorded these conditions: 0.7% of hours (!!).

Climate change has certainly resulted in historic changes in windsurfing winds, but it doesn’t explain the recent significant reduction in east winds: In the 1980s, conditions at Backyards were excellent for wind surfing approximately three days a week; in the 2002-2009 period, conditions at Backyards were excellent for wind surfing approximately once per week and those conditions held for long periods of the day. In the 2014-2017 period, conditions have been suitable for wind surfing an average of once per month; the wind conditions often last for only a few short hours; and wind surfers very often now rely on using their lightest boards and larger sails for conditions to even be sailable. The reduction in the observed frequency of strong offshore E, ESE, and SE winds used by wind surfers has been strikingly more dramatic (as informally evidenced by the 0.7% of hours statistic from the “backyard” weather sensor) than the relatively small reduction documented at the James Campbell weather station for the 2014 – present period.

All of this wind data is available to the public; wind rose software can be downloaded free. Data download and software installation takes 30 minutes the first time of use; subsequent looks at the data, like what we did today, take literally five minutes. We would be happy to help you download the software and weather data so you can assess the data independently in any way you’d like.

Given the changes observed at Sunset Point in relation to the data presented here, surfers have cause to be concerned about the installation of a second, even taller, wind farm upwind from the North Shore’s important surf spots. Sunset Point’s very dramatic local reduction in the frequency and strength of our east winds and the dramatic increase in side-onshore wind direction is not reflected in the data from the James Campbell weather station, located upwind from the Kahuku Wind Farm. We have two scientific-grade wind sensors en route to Hawaii, and we would be happy to collaborate in partnership with the Kahuku Wind Farm or Champlain wind energy companies to give further study to the subject. It’s worth noting we’ve tried and failed to make contact with Kahuku Wind Farm’s current owner: NRG purchased SunEdison’s Hawaii holdings, but Charlie Toguchi, who introduced himself to the North Shore Neighborhood Board as NRG’s representative, informed us by phone on February 10, that NRG is not involved with the Kahuku Wind Farm. Since we plant to prepare and request an ordinance requiring the Kahuku Wind Farm (and Na Pua Makani Wind Farm, should it be constructed) to feather rotor blades under certain easterly wind and buoy swell conditions, it seems it would be beneficial for the wind farm(s) to coordinate closely with us, so we’ll continue to work to make contact with the Kahuku Wind Farm’s new owner

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March 12, 2017 post-script: Dear wind developer, Sop denying wind farm effects reach many miles downwind from the wind farm (we sent the following graph to the email distribution list:

March 13 Email to wind developer: Aloha, The attached 2005 publication [from Remote Sensing of the Environment] will help you visualize the loss of wind speed many miles downwind from wind farms:

For Comparison with the map above, here are our local wind farms, surf spots, and distances:

Sunset Point surfers have lost their east winds due to the Kahuku Wind Farm three miles upwind from the surf spots; new data analysis shows us the loss of east winds is not attributed to climate change. Wind direction is very important to surf quality. Offshore winds are important on the North Shore because they groom wave faces, hold wave faces up and allow them to build taller and steeper before they break, create hollow fast waves, and contribute to creation of larger longer barrels. Onshore winds = bumpy wave faces. Local surfers have noticed significant recent changes in winter wind conditions at Sunset Point since the Kahuku Wind Farm was built. The east and southeast down-valley offshore winds are no longer dominant; east winds are less filled-in/more inconsistent so northeast (side-shore) winds dominate. We now attribute the loss of these offshore winds to the reduced strength of the wind to the 2011 Kahuku Wind Farm because wind data shows us the east winds we used to get are still there – on the upwind side of the wind farm. In the recent period since the wind farm was built, ten-minute average wind speeds are as strong or stronger upwind from the wind farm than they were in the eight years immediately prior to wind farm construction. This new understanding of the wind farm effect to the winds is even more concerning because a new wind farm called Na Pua Makani, which would be 650 feet tall (58% taller than any other wind farm in Hawaii), is proposed at the location just south of the Kahuku Wind Farm (Figure 2), downwind from Pipeline, the North Shore’s premier surf break. This proposed new wind farm would widen the curtain blocking the North Shore’s easterly wind flow. We’re very concerned the Na Pua Makani wind farm will weaken the offshore wind flow at Pipeline. Please consider making a donation to protect our existing wind conditions at Pipeline and Sunset Beach from the proposed construction of the Na Pua Makani Wind Farm at http://www.keepthenorthshorecountry.org/donate/. The proposed wind farm’s endangered bat and NEPA aspects don’t meet State and Federal law, so a court will agree they can’t break ground on the project as it’s currently proposed. Wind farm tax credits expire at the end of 2019.

Description of the Sunset Point Area Surf Breaks: Sunset Point area surf spots include Backyards and Phantoms – Revelations and Velzyland are adjacent surf breaks to the North; Sunset Beach surf break is an adjacent surf break to the south (Figure 1). NE and ENE winds are side-offshore (blowing across the front of the wave face) at Backyards, Revelations, and Velzyland. Due to the way the reef is oriented, ENE winds are more offshore at Sunset Beach and Velzyland. Where Revelations breaks outside/far from shore, NE winds are side-shore. Where Revelations breaks closer to shore, the wind NE and ENE wind is more offshore as the wave face becomes oriented more to the ESE as it bends to the contour of the reef. Therefore, wind that is side-shore when you first catch the wave at Revelations, becomes more offshore on the inside areas of Revelations. The same NE and ENE wind would be considered more offshore at Velzyland and inside Revelations. Surfers prefer east to southeast winds less than 15 mph; wind- and kite-surfers prefer strong NE winds (15-30 mph); many kite surfers avoid Backyards when winds are SE. We refer to winds by their compass direction because “tradewind” can refer to any wind with an easterly component, because wind preferences vary among surf locations and among types of surfers, and because wind that is considered more onshore at one surf break could be considered more offshore at an adjacent surf break.

Description of the Prevailing and Local Winds: Our discussion is limited to winter surf season (October 1 through March 31). Prevailing winds are easterly (NE to SE) interrupted by periods when wind direction clocks to the south, west, and north around cold fronts. On days with prevailing wind conditions, the following noticeable patterns regularly occur at the Backyards to Revelations surf breaks: Before Kahuku Wind Farm was constructed (and in periods when it is shut down), around 9 or 10 am, the surf faces become “cleaned up” smoothed off when east or southeast wind flows used to fill in for the day. East winds came directly offshore and down-valley winds often flowed from Kaunala Valley. These east winds and down-valley winds resulted in frequent, perfect, offshore wind conditions at the Backyards, Phantoms, Velzyland, and inside Revelations surf breaks. These east and down-valley winds of varying strength would influence most of the local surf breaks on most days. On days when the prevailing tradewind is from the NE or ENE, the local SE down-valley winds battle with the sideshore winds. They would often meet in the Phantoms vicinity – the SE winds would dominate the nearshore areas and the side-shore wind would dominate at Revelations. When winds were strong enough to be visible on the ocean surface, you could visibly see the SE down-valley winds blowing across the ocean surface to the vicinity of inside Phantoms at the same time you could see the NE or ENE winds blowing at Revelations. Usually, Revelations winds were not influenced by the down-valley SE wind flow – northeast winds always dominate out at this break. Since the Kahuku Wind Farm became operational, east winds and the down-valley winds from Kaunala Valley are much weaker and the east and SE down-valley winds are no longer the dominant wind pattern at the Backyards to Phantoms surf breaks. Due-east tradewinds are coveted at most surf spots – they are offshore at most locations. When a rock wall, large buildings, and large trees come on to the landscape near shore, surfers notice east winds are lessened behind the structure. Having just passed through the Kahuku Wind Farm, east winds are now much less “filled in” at the Backyards to Revelations surf spots. They are much more turbulent and inconsistent. The northeast sideshore winds now dominate. What all of this loss of east and southeast winds translates to, to an untrained eye, to the non-surfer living at Backyards, is that when you go down to look at the wave faces from Backyards to Revelations, you don’t see clean and smooth wave faces as often as you did the years before the wind farm was constructed.

Wind turbines cause turbulence (visible in Figure 2). Because we’d read aircraft safety and other precautions related to turbulence extend only a mile or two from wind farms and Sunset Point is three miles from the Kahuku Wind Farm, we had previously attributed much of the wind change to climate change. Climate Change has had clear and noticeable changes in surf quality, but these changes have been occurring over a long period of time: ocean swells were stronger in the 1970s and 1980s and winds were very frequently strong (18 – 30 mph) and good for wind surfing at Backyards and Revelations prior to 2000. Our analysis of wind data from stations upwind and downwind from the Kahuku Wind Farm indicate climate change is not responsible for the significant change in the strength of the east winds and Kaunala Valley’s down-valley winds. We believe the Kahuku Wind Farm is primarily responsible for the loss of the down-valley SE wind conditions and the inconsistency in the east winds. This new wind analysis alarms us because it shows the wind strength that would feed the down-valley SE winds is still relatively unchanged at the weather station upwind from the Kahuku Wind Farm. This new understanding of the winds is even more concerning because a new wind farm called Na Pua Makani, which would be 650 feet tall (58% taller than any other wind farm in Hawaii), is proposed at the location just south of the Kahuku Wind Farm (Figure 2), downwind from Sunset Point and from Pipeline, the North Shore’s premier surf break.

Figure 2. Wake turbulence is usually not visible to the eye as it is in this photograph. In this photo, the air temperature was very close to the dew point so visible clouds formed when energy was removed from the air by the turbines. The wind turbine disturbance of the visible smooth laminar air flow with eddys and vortices is visible because of the fog (http://www.dgem.nl). (For scale, large windmills are spaced about a half a mile apart.)

Details of Wind Analysis: Figure 1 shows the locations of the upwind and downwind weather stations (green dots) examined in the analysis in relation to the existing Kahuku Wind Farm (installed in 2011 and the North Shore but faltering in early operations due to fires), and the Pipeline to Revelations portion of the North Shore. Winds are labeled arrows. The weather station wind analysis compares wind speed and direction in the period prior to Kahuku Wind Farm installation to the 2012-present period after the wind farm became operational at two weather stations; one upwind and the other downwind from the Kahuku Wind Farm. The wind analysis uses readily available weather data and software – it would take 30 minutes for you to repeat it – contact us if you’d like assistance running the analysis.

The winds at the weather stations behind (downwind) and in front of (upwind) the Kahuku Wind Farm are shown in Figures 3 and 4. We were not surprised to see the changes in wind reflected in the before and after wind rose graphs for the weather station downwind from/behind the Kahuku Wind Farm (Figure 3). The wind rose shows quite a significant reduction in the strength of East and ESE winds after the wind farm became operational. We believe this reduced wind strength due to the wind farm is the cause of the significant reduction in the strength of the down-valley offshore winds at we’ve seen at the surf spots at the mouth of Kaunala Valley (Backyards and Phantoms).

Figure 3. Significant reduction in surf season daytime trade wind 10-minute average wind speeds recorded before (left) and after (right) Kahuku Wind Farm construction/operation at the Kahuku Training Area weather station (½ mile downwind from the Kahuku Wind Farm). Strength of East and ESE winds is significantly reduced after the Kahuku Wind Farm became operational versus before the wind farm was constructed. Winds downwind from the wind farm are squirrely winds from other directions, indrafts of wind blowing in toward the leeward side of the wind farm due to eddys/vortices behind the windmills. We’re relieved the very significant proportion of hours with west winds shown in the recent wind data at this wind farm, which must be due to very strong eddys in the immediate vicinity of the wind farm don’t reach Sunset Point. However, the reduced strength of the East and ESE winds seems to be closely related to the very significant reduction in the periods when down-valley offshore wind direction dominates at Backyards/Sunset Point.

What’s really unexpected is that the strength and consistency of winds at the weather station located one mile upwind from the wind farm are not very different now then they were before (Figure 4). The significant number of hours of consistent strong east winds (the green and blue bars in Figure 4) are still reflected in the upwind weather station’s recent years’ wind data. Because the very significant loss of wind strength we would expect to see if climate change were responsible for the recent significant loss of down-valley offshore winds at Sunset Point is not present, and because the loss of the down-valley winds has been so striking since the wind farm became operational, it’s very difficult for us to attribute the loss of offshore winds at Sunset Point surf breaks to climate change.

Figure 4. The strong consistent daytime surf season winds are still present at the weather station located one mile upwind from the Kahuku Wind Farm. There has been very little loss of trade wind 10-minute average wind speed in the recent period since the Kahuku Wind Farm operation (right) versus the period prior to the wind farm’s construction (left). The green and blue bars in the graph at the right indicate strong, consistent (10-minute average, uninterrupted by wind-farm lulls/gusts) easterly winds are still present at this location (unlike the wind rose graphs in Figure 3 showing data from the weather station situated downwind from the wind farm and the wind we feel at Sunset Point).

On the bright side, we are relieved because the degradation of winds that is caused by the wind farm could be avoided; we’ll ask the Kahuku Wind Farm to feather their blades to minimize their effect on the down-valley, offshore winds at Sunset Point when good swells are registering on the Waimea buoy. We’ll also do what we can to prevent construction of the Na Pua Makani Wind Farm upwind from Pipeline, and if it gets built, we’ll work to ensure blades are feathered when swells are good.

Next Steps: Addressing the Kahuku Wind Farm: We’re drafting swell and wind conditions under which we would like the Kahuku Wind Farm to feather its blades to minimize adverse effects to our surf conditions at Sunset Point October 1 through March 31 during the daytime. We’re working with surf forecasters to develop Waimea buoy swell conditions under which the turbine blades should be feathered to avoid adversely affecting surf conditions. Draft conditions (we are working with surf forecasters to refine) under which we would like Kahuku Wind Farm to feather their blades when wind direction at the upwind turbine at the wind farm measures ENE, E, and ESE: There are essentially four types of surfing: surfing (paddle surfing), wind- and kite-surfing, tow surfing, and stand up paddle surfing. Best surfing: Buoy swell 4-feet, 11-second period or higher and winds under 15 mph; Tow surfing: Buoy swell 10-feet, 16-second period or higher and winds under 15 mph; Wind surfing: buoy swell 4-feet, 11-second period or higher and winds 18-35 mph; Kite surfing: 12-25 mph winds.

Next Steps: Addressing the Proposed Na Pua Makani Wind Farm: It’s not illegal (based on current laws) for the proposed Na Pua Makani Wind Farm to further degrade our surf wind conditions (or to cause significant harm to the Kahuku community), but several aspects of the proposed wind farm don’t meet requirements of State and Federal law. It is, for example, illegal to kill endangered bats without offsetting the take and Na Pua Makani’s mitigation proposal doesn’t even claim to produce one single new bat let alone offset the 51 bats they request authorization to kill. Na Pua Makni also seems to be trying to get a license for a smaller amount of bat take than they will need – maybe to get the project built now and deal with the realities of the project’s actual bat take later. For instance, Na Pua Makani calculated their anticipated bat take based on per-turbine bat mortality at the Kahuku Wind farm (314-foot rotor diameter) though their Na Pua Makani turbine rotor diameter would be a much larger 427 feet. Na Pua Makani also claims their bat take will be reduced by 65% due to implementation of low wind speed “curtailment”, even though curtailment hasn’t proven to reduce bat take at the existing Hawaii wind farms. It’s also worth noting that in 2013, the public requested that a solar alternative to the proposed wind farm be included among the alternatives presented and analyzed in the project’s EIS and that alternative has not been provided. Once the less harmful solar alternative is disclosed in the EIS, we hope the permitting agencies will be hard pressed to select the wind farm as their preferred alternative.*

Keep the North Shore Country, Kahuku Community Association, and several other groups that would be severely affected by the proposed wind farm were granted a contested case before the Board of Land and Natural Resources to help assure Na Pua Makni follows State laws. We are fundraising for Keep the North Shore Country, a 501(c)(3) nonprofit, to help them secure funding to pay for bat specialists and retain an environmental lawyer for the contested case hearings. Keep the North Shore Country’s petition is online here: https://dlnr.hawaii.gov/wp-content/uploads/2016/12/C-1.pdf. The Hawaiian hoary bat information gathered in this Na Pua Makani contested case will be useful in informing any other developer who tries to move forward with a wind farm anywhere near the North Shore, including the Ka’ena Point ocean wind farm and extensions of any permits or licenses for the four very visible wind turbines at Waimea Bay. The information Keep the North Shore Country gathers in the contested case effort would also inform any State or Federal litigation that could be necessary if the contested case hearings fail to cure the Na Pua Makani Wind Farm’s glaring deficiencies. In a Waialua meeting on January 26, 2017, HECO’s vice president and other representatives assured us that future North Shore wind development including the Na Pua Makani Wind Farm is not a necessary part of clean energy plans – they told us they had initially rejected Na Pua Makani’s application and the wind developer had to contest the decision to get as far in the planning stages as they have.

*This is a personal weblog. The information presented here represents the concerns of local Sunset Point surfers, concerns raised by Keep the North Shore Country, and data from contributing weather specialists. The concerns expressed here are not made by or on behalf of any agency or entity with connections to wind farm permitting or authorization

November 26, 2016, Draft of Letter to Department of the Interior Secretary, 1849 C Street, N.W., Washington DC 20240 from Surfers with Notable Experience on the North Shore of O‘ahu

Dear Secretary of the Interior,

We are pro-green energy surfers writing to ask you not to authorize development of wind farms in areas where they would damage O‘ahu’s North Shore surfing conditions because environmentally preferable alternatives, such as solar photo-voltaic (PV), are readily available, reasonable, and feasible. Please don’t allow at-sea wind platforms where they would cause diffraction of inbound open ocean swells and please don’t permit wind turbines in areas on land or in the ocean where they would disrupt the offshore winds that power our wind- and kite-surfing sails and groom our clean wave faces. Your website indicates your Department is “Protecting America’s Great Outdoors and Powering Our Future” and we believe you can achieve both by assessing and selecting solar PV with energy storage alternatives to the proposed wind farms. Maps of areas that should be excluded from wind farm development to conserve North Shore surfing’s ocean swells and offshore winds, and an example of North Shore acreages that should be considered for solar PV development, are shown in Figure 1.

Figure 1. Areas to avoid wind farm development (top) and areas that should be included in solar PV alternative analysis.

Until the solar alternatives and other less harmful, readily available energy solutions are exhausted, please don’t select harmful wind farm development as your agency’s preferred alternative. We believe Hawai‘i’s clean energy needs can be met without harming Hawai‘i’s “Great Outdoors” in the process.

The North Shore has seven miles of surf spots – the “Seven Mile Miracle” that would be adversely affected by wind farm development in the open ocean through which the swells pass to reach the North Shore or wind farm development downwind from the surf breaks. The quality, energy, and “cleanness” of surf would be reduced and disturbed if they passed by and through large heavy floating structures before reaching shore. The surf breaks that line the North Shore’s coast derive their perfect, clean wave face conditions from relatively strong, consistent offshore wind flow. Pipeline (Figures 2-6), the most famous surf spot in the world, and one of the most perfect waves in the World, is located due east of one of the at-sea wind farms under consideration by your Department and it is downwind from a land-based wind farm permit you’re currently assessing.

Hawai‘i, O‘ahu, and the North Shore’s number one economic driver is Tourism. Tourism is a $14 billion part of our economy, accounting for 22% of our GDP. More than 50 % of O‘ahu tourists tour the North Shore during their stay. Tourists spend an average of $150 to $400 a day in Hawaii. The economy of the residents of the North Shore is rooted in the beauty of our scenery, our clean powerful surf conditions, and our undeveloped country environment. Your proposed wind farms would adversely affect the availability and quality of surf available to the World population of surfers. The Hawai‘i Tourism Authority prioritizes “Maintaining the Brand” to assure long-term sustainability of the destination. Your proposed wind farms would cause irreparable harm to the North Shore brand and to our surfing-based economy.

A review of the 2010 Census data indicates the North Shore receives the following total annual value of sales: Retail $105,649,000; Food: $33,591,000; Rental Real Estate (including Turtle Bay Resort): $5,367,000 for a total annual tourism-related input of $144.6 Million. A 10 percent reduction to this net would cost our tourist-related businesses $14.4 Million annually. Your analysis of the effects of the proposed action should include an assessment of changes to the future number of tourists visiting the North Shore and the tourist dollars spent on the North Shore the projects may have.

In May 2016, the Department of Interior’s Bureau of Ocean Energy Management provided a map of ocean areas they consider to be suitable for wind development (Figure 7, top) and in July 2016, they selected and enlarged a portion of the area (Figure 7, bottom) and invited wind farm lease requests.

Figure 7. Department of Interior maps delineating the area BOEM considers to be suitable for wind development (top) and their Oahu North ocean area two wind developers have asked to lease.

One ocean lease applicant for the northern “call area” (an entity called AW Wind Hawaii, LLC which is led by a Danish citizen, Jens [pronounced Yens] Peterson) proposes to build at least 51 floating windmills, and is clearly trying to reserve the option to build many more, possibly 100 or more. Each floating windmill is proposed to be built on a patented “Wind Float” platform similar to the photo shown on the applicant’s application. The photo on the application is of a single demonstration Wind Float windmill that was built in northern Portugal. The in-water portion of a floating wind structure is shown in Figure 8 (in shallow water, without anchors).

The Wind Float platform that was built in northern Portugal is anchored in water that is only 40 to 45 meters deep. In contrast, the waters in much of the northern “call area” off Ka‘ena Point are about 1,000 meters (3,300 feet) deep. That is 5 to 6 times deeper than anyone anywhere in the world has ever successfully anchored floating windmills, and more than 20 times deeper than the applicant’s demonstration Wind Float in Portugal.

The small-scale demonstration Wind Float in Portugal is anchored by four steel-cabled anchor lines that spread out in four directions. The small-scale Wind Float itself consists of three large steel semi-submersible cylinders that have a diameter of 10 meters each (33-feet diameter each (the width of our houses), and extend down more than 70 feet into the water. The three cylinders are set in a triangle held together with various steel tubes and cross braces, and the windmill tower sits on one of the three cylinders. The single demonstration Wind Float in Portugal has a 2.4 MW (megawatt) Vestas brand wind turbine. For Hawaii, the applicant is proposing to use wind turbines in the 6 to 8 megawatt (MW) range. As a result, the size of the Wind Float cylinders that would be needed in Hawaii will be even larger than the ones used in Portugal.

Even with the smaller size of the Wind Float in Portugal, the total cross section of steel for each Wind Float will be 99 feet (three times the 33-foot diameter for each cylinder). Each cylinder would extend more than 70 feet down into the water, and then connect to the anchor cables. Even if only that smaller-sized Wind Float were built, and even if the applicant only built 51 of the windmills, which would mean a total metal cross section that waves will have to hit of about 1 mile. (51 times 99 feet equals 5,049 feet, and there are 5,280 feet in a mile.) If the applicant ends up building 100 larger sized Wind Float windmills (to accommodate the 6MW to 8 MW wind turbines it plans), then the total cross section of metal, that waves will have to hit, would be more than 2 miles.

Perhaps even more important than the one to two miles of total metal cross section that waves will run into, is the shape and configuration of the metal. The portion of a wave hitting and passing through a single Wind Float will have three large 33-foot-diameter metal cylinders (or larger) in a triangular shape in relatively close proximity to each other. As the waves hit a metal cylinder they will ricochet off in both directions laterally, and portions of the ricocheted wave energy will hit the other 33 foot cylinders almost immediately. As a wave hits and passes by the cylinders, the interactions of the deflected energy will be very complex. The deflected wave energy will soon move laterally (on an angle) enough to interact with deflected wave energy from the adjacent windmill in that row, as the diffracted waves wedge into each other (Figure 9). In addition to at least some net loss of swell energy reaching the world famous North Shore surf breaks and the Westside surf breaks, there is likely to be a very a significant increase in the messiness of the swell energy (in other words, a decrease in the “cleanness” of the swell energy that surfers want) as it hits and passes through the Wind Floats.

The problems with the decrease in “cleanness” of the wave energy, and increase in the messiness from the random deflected waves, will further increase as the wave and swell energy passes through the next row of Wind Float windmills. The North Shore’s powerful swells are generated thousands of miles away in the open ocean areas of the western and northern Pacific. Once energy is taken out of the swell and once diffaction disturbances are introduced, it wouldn’t somehow be “reconstituted” as the swell moves toward shore, it would be lost. There is no question the giant floating structures that are currently proposed, would adversely affect our west swells.

In August 2016, in our discussions among ourselves regarding the proposed offshore wind farm, we realized many of us have already noticed changes in wind we believe are related to the two realtively-new existing North Shore O‘ahu wind farms. These wind farms seem to be taking energy out of the wind and reduced consistency of wind flow (Figures 10 – 12). This has reduced the cleanliness of the wave faces and affects the consistency of the wind used by windsurfers and kite surfers.

Figure 10. Wake turbulence visible in clouds formed when energy is removed from wind cools and reaches dew point (http://www.dgem.nl).

Wind conditions on windy days (when winds are above 18 mph) are especially important to windsurfers and kite surfers at Mokuleia and at the surf spots located between Sunset Beach and Malaekahana. Sunset Point wind surfers, surfers, and ocean paddlers have noticed that since the wind farm was built four miles due east of Sunset Point six years ago, east winds on windy days are “more gusty”, more “crinkely” and less “filled in”. Gusty less consistent strong winds result in bumps on the wave faces and lulls in wind used by windsurfers and kite surfers surfing large heavy waves.

Surfers and summer paddleboarders at Waimea Bay are affected by the reduction in consistency and cleanliness of the offshore down-valley winds by the wind farm located immidiately adjacent to the shore. Surf faces at Waimea are bumpier because off-shore winds are more disorganized as a result of the recently-installed wind farm.

These changes in conditions from the existing wind farm has reduced the number surfable days and reduced the quality of surf conditions. It also increases surfing injuries. The additional wind turbines proposed for installation downwind from the North Shore would be even larger than the existing ones so they would be likely to cause even further deterioration of our wind and wave face conditions.

Figure 12. Strong offshore wind is critically important to clean wave faces with fewer bumps at Waimea Bay (Photo of Mason Ho and John Florence by World Surf League (WSL), Keoki).

These adverse effects to wind were not disclosed to the public in NEPA documents for your existing wind farms so please ensure these effects are included in your assessments of your proposed projects. Please don’t erect any more wind farm structures in the areas shown in Figure 1 and once existing permits have expired, please don’t re-authorize the two existing wind farms. Doing so would cause unnecessarily deterioration of the North Shore’s offshore wind conditions. The proposed windmills should not be constructed or re-powered because there are readily available, feasible solar PV alternatives that wouldn’t harm the human and natural environment.

We notice many members of the public indicated a preference for a solar alternative in the NEPA scoping comments you’ve received for the proposed wind projects. The National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 97-258, § 4(b), Sept. 13, 1982) (NEPA) requires you to “objectively evaluate all reasonable alternatives” and to “Include reasonable alternatives not within the jurisdiction of the lead agency.” You are pursuing these projects to help meet Hawai‘i’s clean energy needs. Therefore, please ensure NEPA analyses your Department conducts related to these wind farm developments include assessments of a solar alternative that would meet the same energy need as the proposed wind farm. We feel it is the Department of Interior’s responsibility, pursuant to the NEPA, to always assess a solar alternative to any proposed wind farm. We believe that within the State of Hawai‘i, the solar alternative will (until better technology becomes available) always be the environmentally preferable alternative to any wind farm project. Given the risks to resources which are entrusted to your Department, we would expect solar to be your Department’s preferred alternative within the State of Hawai‘i.

The landowners/lessees of the 4,500 acres of flat agricultural lands designated as grazing lands in Figure 1 are interested in solar PV. Several of them already have experience grazing cattle, sheep, and goats under arrays of solar panels. An example grazed solar farm is visible on Highway H-2, south of Mililani Technical Park Exit 7. Solar PV development on the North Shore’s flat grazing land areas would provide more power than the two currently-proposed wind farms combined. This assumes 40% efficiency of the wind farm (best-case scenario); if wind turbine efficiency in this harsh at-sea environment is 20% due to maintenance issues, solar on just half the area highlighted in Figure 1 would provide power equal to the proposed wind farms. Additional flat grazing land is located in other areas of O‘ahu and in large grazing areas on the nearby Neighbor Islands, not to mention all the rooftops, roads, and other existing developed areas that could be outfitted with solar. Sites for solar PV development are vast and sufficient to power urban Honolulu without having to erect any more wind turbines in areas where they would cause great harm to the natural and human environment.

To provide energy at night, solar PV should be paired with energy storage such as batteries, Hydrogen (from electrolysis), or hydroelectric system development. Solar PV installation should be limited to existing developed areas and grazing land; more productive agricultural land should be reserved for food crops. These solar PV and energy storage systems are currently readily available, reasonable, and feasible. There is more than enough suitable land and interested landowners to power urban Honolulu with solar PV so that our surf, our communities, and our natural resources need not be so greatly harmed by unnecessary wind farm developments.

Please don’t authorize wind farms in areas where they would damage O‘ahu’s North Shore surfing conditions because environmentally preferable alternatives, such as solar photovoltaic PV, are readily available, reasonable, and feasible. Because the harmful effects of your proposed wind farm projects extend well beyond adverse effects to North Shore surf conditions, and because solar PV does not have such serious unmitigatable adverse effects, we hope your Agencies will select solar as their preferred alternatives to the proposed wind farm projects. Until the solar alternatives and other less harmful, readily available energy solutions are exhausted, please don’t select harmful wind farm development as your preferred alternative. We believe Hawai‘i’s clean energy needs can be met without harming Hawai‘i’s (and the International surfing community’s) “Great Outdoors” in the process.

We notice many members of the public indicated a preference for a solar alternative in the NEPA scoping comments you’ve received for the proposed wind projects. The National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 97-258, § 4(b), Sept. 13, 1982) (NEPA) requires you to “objectively evaluate all reasonable alternatives” and to “Include reasonable alternatives not within the jurisdiction of the lead agency.” You are pursuing these projects to help meet Hawai‘i’s clean energy needs. Therefore, please ensure NEPA analyses your Department conducts related to these wind farm developments include assessments of a solar alternative that would meet the same energy need as the proposed wind farm.

Please don’t authorize wind farms in areas where they would damage O‘ahu’s North Shore surfing conditions because environmentally preferrable alternatives, such as solar photovoltaic (PV), are readily available, reasonable, and feasible. Because the harmful effects of your proposed wind farm projects extend well beyond adverse effects to North Shore surf conditions, and because solar PV does not harm the environment, we hope you will select solar as your preferred alternative to the proposed wind farm projects. Until the solar alternatives and other less harmful, readily available energy solutions are exhausted, please don’t select harmful wind farm development as your agency’s preferred alternative. We believe Hawai‘i’s clean energy needs can be met without harming Hawai‘i’s (and the International surfing community’s) “Great Outdoors” in the process.